Boston Must Lead By Example — 2019 Climate Action Plan Update

The City of Boston recently published its Climate Action Plan (CAP) 2019 Update, which lays out a five-year decarbonization roadmap aligned with the ultimate goal of carbon neutrality by 2050.  BCAN volunteers have taken a close look at the part of the CAP that relates to reducing carbon emissions from existing buildings, since this sector accounts for more than half of Boston’s total greenhouse gas emissions.

One of the key ideas outlined in the CAP is that of carbon emissions performance standards,  mandatory carbon emissions targets by building type that decrease over time. The emissions standards would be established by amending the City’s Building Energy Reporting and Disclosure Ordinance (BERDO), which currently applies to buildings of 35,000 or more square feet. The process of developing these standards will begin in 2020, and the City expects to propose an amendment to BERDO in 2021. 

Establishing building performance standards is an important step forward toward carbon neutrality.  Low-carbon buildings save money and bring better health to occupants. Setting standards would give property owners clear mandates to guide their maintenance schedules and would show that the City is taking climate change seriously.

We applaud the City for recognizing that establishing performance standards is a crucial element of what must get done in the next 5 years if we are to meet our 2050 goal. We value the public process that must precede putting more teeth into BERDO, but given that we are in a climate emergency, we are concerned that the City’s timeline for retrofitting existing municipal buildings seems very slow.

According to the CAP, the City intends to reduce annual emissions from municipal buildings by a mere one percent in 2019, plus an unspecified “additional emissions reductions” in 2020 and beyond.  Municipal building upgrades are not dependent upon a public process, and an explicit and ambitious timeline for deep energy retrofits of every City-owned building must be made public in 2020. The goal for carbon neutrality in City-owned buildings should be set much sooner than for private buildings.

We are also concerned that there is no plan to address existing buildings under 35,000 square feet. In the near-term, the threshold for BERDO should be lowered.  Also, two promising ideas that would benefit many residents should be pursued: rental energy efficiency requirements and energy scorecards that must be made public when a property is rented or sold.  Scorecards would empower buyers and renters and create a market-based incentive for owners and landlords to reduce fossil fuel consumption. Both of these ideas should be researched, and if possible established, within this current 5-year plan.

Lastly, we are concerned that the CAP does not address enforcement penalties for non-compliance with BERDO.  At present a number of building owners regulated by BERDO have not even complied with the existing mandate to make public their energy use data. Given Boston’s extreme vulnerability to flooding and heat waves, and the consequences of climate change for those worldwide who have contributed the least to the climate emergency, we must use sticks as well as carrots to push Boston’s building owners to decarbonize as quickly as possible.

Read more about our campaign to strengthen and expand Boston’s Building Energy Reporting and Disclosure Ordinance (BERDO) at https://bostoncan.org/green-buildings/.

You can find Boston’s website about BERDO at https://www.boston.gov/departments/environment/building-energy-reporting-and-disclosure-ordinance.

You can read more about Boston’s Climate Action Plan at https://www.boston.gov/departments/environment/boston-climate-action#climate-action-plan.

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